New and Interesting International Tax Issues

Other - Resources

April 20, 2017

Recently, the IRS published 11 new International Practice Units (“IPUs”) on its website. We have updated our resource page that categorizes the IPUs by topic. The new IPUs include: IRC 367(d) Transactions in Conjunction with Cost Sharing Arrangements (CSA) Hedge Fund Basics Summary of Foreign and Domestic Loss Impacts on the Foreign Tax Credit How to Assess Penalties for Failure to File Form 8886 Disclosing IRC 988 losses Sourcing of Exchange Gains or Losses in...
Read more →

December 29, 2016

Recently, the IRS published 5 new International Practice Units (“IPUs”) on its website. We have updated our resource page that categorizes the IPUs by topic. The new IPUs include: Employee Share of Employment Taxes - U.S. Citizens and Resident Aliens Working Abroad Self-Employment Taxes - U.S. Citizens and Resident Aliens Working Abroad Portfolio Debt Exemption – Requirements and Exceptions Source of Income for Nonresident Alien Individuals Identifying Foreign Goodwill or Going Concern
Read more →

August 05, 2016

The IRS drafts publications that summarize in plain English U.S. tax rules for a variety of tax topics. A few of the publications discuss U.S. international tax issues. However, most of the IRS international publications deal with the U.S. taxation of individuals, and not with the U.S. taxation of businesses. For example, IRS publications do not cover Subpart F Income, outbound transfers to foreign corporations, transfer pricing, etc. To learn about these rules, one would...
Read more →

August 14, 2015

Below are several interesting authorities or publications related to international tax that have been released recently. The U.S. Senate Permanent Subcommittee on Investigations (PSI), held a hearing on July 30, 2015 exploring the impact of the U.S. corporate tax code on foreign acquisitions of U.S. businesses and the ability of U.S. businesses to expand by acquisition. The associated report, "Impact of the U.S. Tax Code on the Market for Corporate Control and Jobs," details transactions...
Read more →

December 23, 2014

Last week the I.R.S. published 46 International Practice Units. The Practice Units provide I.R.S. staff with explanations of general international tax concepts as well as information about specific types of transactions. The 46 topics covered in the Practice Units are shown below. In addition, we have added a link to the Practice Units in our “Resources” section in the right column. Interest Income Derived by CFC or QBU Engaged in Banking Financing or Similar Business...
Read more →

January 17, 2014

Today we have added a new resource page to the blog: 2013 developments in U.S. international tax. The page lists and summarizes the significant cases, administrative materials (regulations, announcements, notices, etc) released by the IRS, and other 2013 developments related to U.S. international tax. The resources section is located on the right hand side of the page just below Tax Blogs.
Read more →

December 04, 2013

Today we have added a new link in the "Resources" section of the blog: monetary penalties for failure to file common U.S. international tax forms. The table includes the general civil penalties for failure to file the forms. Other penalties, such as denial of deductions and criminal penalties are not in the table. The resources section is located on the right hand side of the page just below Tax Blogs.
Read more →

November 26, 2013

We have added a new "Resources" section to the blog, located on the right hand side of the page just below Tax Blogs. Thus far we have added pages with links to the common U.S. international tax forms as well as the I.R.S. publications on international subjects. We plan to add more resource pages. We will let you know as we do.
Read more →

Popular Categories

Disclaimer

The posts on this blog have not been verified for accuracy. You should consult an attorney for legal advice regarding your own situation. These posts are not updated for changes in the tax laws. Further, these posts should not be relied upon for any purpose whatsoever.